For Pillar Three Disclosure please contact Olive Gibson Salt Rock Capital Partners LLP - UK Stewardship Code Disclosure Statement Under COBS 2.2 of the FCA Handbook, we are required to make a public disclosure in relation to the nature of our commitment to the above Code, which was published by the Financial Reporting Council (the “FRC”) in July 2010. The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a “comply or explain” basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle. The seven principles of the Code are that institutional investors should: • publicly disclose their policy on how they will discharge their stewardship responsibilities; • have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship; • monitor their investee companies; • establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value; • be willing to act collectively with other investors where appropriate; • have a clear policy on voting and disclosure of voting activity; and • report periodically on their stewardship and voting activities. Salt Rock Capital Partners LLP does not currently comply with the Code for the following reasons: • our Global Macro investment strategy involves mainly futures, foreign exchange and other mainly highly liquid OTC financial products which do not relate to the instruments of listed UK companies; • as such we do not normally invest directly in listed UK companies, where we would be able to engage as anticipated by the Code (including having proxy voting rights). Should any of the above factors change (including having proxy voting rights where we have invested in a UK company), we will review our commitment to the Code at that time and make appropriate disclosure. For further details on any of the above information, please contact Olive Gibson, COO
Salt Rock Capital Partners LLP is an Investment management firm based in London. Salt Rock follows a discretionary global macro strategy which focuses on policy and changes in policy and trades in the best risk adjusted opportunities that these give rise to.
The principal, Mark Painting has 22 years of financial markets experience, through different market cycles and asset classes. Prior to founding Salt Rock Capital Partners LLP in 2013, Mark was a Senior Managing Director and Partner at Caxton Associates.
Salt Rock Capital Partners LLP is Authorised and regulated by the Financial Conduct Authority.
SRD II aims to improve stewardship and corporate governance by firms, including full scope Alternative Investment Fund Manager that invest in shares traded on a regulated market in the EEA, as well as ‘comparable’ markets situated outside of the EEA. Under FCA COBS 2.2.B.5R, we are required to: 1. develop and publicly disclose an engagement policy that meets the requirements of COBS 2.2B.6R; and 2. publicly disclose on an annual basis how our engagement policy has been implemented in a way that meets the requirements of COBS 2.2B.7R; or 3. publicly disclose why we have chosen not to comply.
The engagement policy must describe how we: 1) integrate shareholder engagement in our investment strategy: 2) monitor investee companies on relevant matters, including: 1. strategy; 2. financial and non-financial performance and risk; 3. Capital structure; and 4. social and environmental impact and corporate governance; 5. conduct dialogues with investee companies; 6. exercise voting rights and other rights attached to shares; 7. cooperate with other shareholders; 8. communicate with relevant stakeholders of the investee companies; and 9. manage actual and potential conflicts of interests in relation to our engagement.
On an annual basis, we must disclose a general description of voting behaviour, an explanation of the most significant votes and reporting on the use of the services of proxy advisors. The disclosure must include details of how votes have been cast, unless they are insignificant due to the subject matter of the vote or to the size of the holding in the company.
Salt Rock Capital Partners LLP has decided that, whilst it supports the aims of SRD II, it has chosen not to comply with the Directive at the present time because the Strategy does not generally invest into individual listed equity securities.